Generally, the designation of an individual with a leadership role in a governing institution does not itself block the governing institution. Accordingly, engaging in a routine interaction with a governing institution in which a blocked individual is an official, but that does not directly or indirectly involve the blocked individual in question, is not prohibited. This applies to any designated individual in Afghanistan who has a leadership role in a governing institution in Afghanistan, including any individual blocked pursuant to the Global Magnitsky Sanctions Regulations (GMSR). For example, making a customs payment to a governing institution in Afghanistan led by a blocked individual would not be prohibited by the GMSR. However, engaging directly or indirectly with that blocked individual, such as receiving an invoice bearing the blocked individual’s signature for a commercial transaction, would be prohibited by the GMSR unless authorized by OFAC or exempt.
In addition, certain humanitarian-related transactions involving individuals blocked pursuant to the GMSR may be authorized by general licenses (GL) in the GMSR related to certain international organizations (IOs), nongovernmental organizations (NGOs), official business of the United States government (USG), or agricultural commodities, medicine, medical devices, replacement parts and components, or software updates for personal, non-commercial use (Ag-Med). For more information on these GLs, please consult OFAC ‘s Supplemental Guidance for the Provision of Humanitarian Assistance and FAQs 1105, 1106, 1107, 1108.
For information on transactions involving governing institutions in Afghanistan led by an individual or entity designated under the Global Terrorism Sanctions Regulations, the Foreign Terrorist Organizations Sanctions Regulations, or Executive Order 13224, please consult Afghanistan-related GL 20 and FAQ 993.
If individuals or entities, including IOs, NGOs, or financial institutions, have questions about engaging in or processing transactions related to these authorizations, they can contact the OFAC Compliance Hotline via email at OFAC_Feedback@treasury.gov.